The term massacre can be defined as a form of action, usually collective, aimed at the elimination of civilians or non-combatants including men, women, children or elderly people unable to defend themselves. The definition may also include the killing of soldiers who have been disarmed. One of the most notorious European examples of the latter was when Soviet troops massacred Polish officers in Katyn in February 1940. There are various definitional problems inherent in the notion of "massacre." For instance, there are divergent interpretations between adversaries, such as can be seen in the Israeli-Palestinian dispute over the tragic events at Jenin in April 2002. The Palestinians labeled the event a massacre, a charge that Israel denied. The Palestinian charge was further undercut by a report from the Secretary General of the United Nations, which challenged the Palestinian claim of hundreds of dead, substituting instead the much...